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The foreign account amnesty is just a put option

The amnesty program for people with undisclosed offshore accounts — it’s just a put option.

Start the process. You have the ability to close off your fight with the IRS on the terms of the voluntary disclosure program (pay tax for 2003-2008, pay 20% of that tax, and interest on all of that, PLUS 20% of the high balance in your accounts) at your option. The IRS can’t force you to accept it.

You hold a put option to resolve all of your tax problems with the IRS for your undisclosed foreign bank accounts by paying that amount of money.